COMMISSION STAFF WORKING DOCUMENT 2022 Rule of Law Report Country Chapter on the rule of law situation in Greece Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions 2022 Rule of Law Report The rule of law situation in the European Union
Date: 2022-07-13
Institutions: European Commission, Secretariat-General
Subjects: Greece, coronavirus disease, corruption, democracy, epidemic, independence of the judiciary, infringement of EU law, pluralism in the media, political rights, rule of law

EN 

  EN 

   EUROPEAN COMMISSION  Luxembourg, 13.7.2022  SWD(2022) 508 final  COMMISSION STAFF WORKING DOCUMENT 2022 Rule of Law Report        Country Chapter on the rule of law situation in Greece Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions 2022 Rule of Law Report          The rule of law situation in the European Union {COM(2022) 500 final} - {SWD(2022) 501 final} - {SWD(2022) 502 final} - {SWD(2022) 503 final} - {SWD(2022) 504 final} - {SWD(2022) 505 final} - {SWD(2022) 506 final} - {SWD(2022) 507 final} - {SWD(2022) 509 final} - {SWD(2022) 510 final} - {SWD(2022) 511 final} - {SWD(2022) 512 final} - {SWD(2022) 513 final} - {SWD(2022) 514 final} - {SWD(2022) 515 final} - {SWD(2022) 516 final} - {SWD(2022) 517 final} - {SWD(2022) 518 final} - {SWD(2022) 519 final} - {SWD(2022) 520 final} - {SWD(2022) 521 final} - {SWD(2022) 522 final} - {SWD(2022) 523 final} - {SWD(2022) 524 final} - {SWD(2022) 525 final} - {SWD(2022) 526 final} - {SWD(2022) 527 final}  
 
 
ABSTRACT 

A number of measures aiming at improving the efficiency and the quality of the Greek justice 
system are being implemented. The 2021 reform of the School of Judges aims at increasing 
the  quality  of  judges’  training,  and  the  planned  creation  of  a  National  School  for  Judicial 
Clerks would help to improve the quality of the assistance to judges and of the management 
of the courts. The revised Code of Civil Procedure in 2021 seeks to have a positive impact on 
the efficiency of justice, in particular as regards delays in civil justice and the coherence of 
the case law. A code of conduct for the judges of the Council of State was adopted in March 
2022. Draft legislation on the promotion of judges and prosecutors and the organisation of the 
courts  was  adopted  by  the  Parliament  in  June  2022.  Measures  are  being  implemented  to 
improve  the  quality  of  justice,  in  particular  as  regards  digitalisation.  The  draft  legal  text  is 
being  finalised  to  create  a  formal  legal  framework  for  the  office  for  the  collection  and 
processing  of  judicial  statistics  established  in  the  Ministry  of  Justice  at  the  end  of  2020. 
Concerns remain regarding the appointment procedure for the most senior positions of judges 
and prosecutors, including the lack of judicial involvement in the selection process.  

The  new  National  Anti-Corruption  Action  Plan  for  2022-2025  was  approved.  The 
cooperation between anticorruption bodies and entities from the private and public sector is 
being developed. Provisions for the regulation of lobbying were recently adopted. A limited 
number of prosecutions  related to  corruption  was taken forward, although progress  on final 
decisions  remains  to be  established.  While the number of  asset declarations being  filed has 
increased  and  all  are  verified  for  their  completeness,  their  accuracy  is  only  verified  in  a 
limited  percentage.  Rules  on  the  ethics  of  civil  servants  continued  to  be  implemented,  but 
concerns  persist  as  regards  the  integrity  within  the  police  force.  Regular  auditing  activities 
aim at detecting and preventing corruption. Specific actions to counter the risk of corruption 
during the COVID-19 pandemic continued to be applied.  

Freedom  of  expression  and  the  right  of  access  to  information  are  legally  and  formally 
protected in the Constitution and sectorial legislation. The Greek government has taken steps 
to  strengthen  the  transparency  of  media  ownership,  through  recently  adopted  legislation. 
However,  the  situation  of  journalists  raises  significant  concerns  due  to  the  fact  that  they 
continue  to  face  threats  and  attacks  while  their  professional  environment  has  further 
deteriorated. The allocation of state advertising as  regards,  in  particular the non-transparent 
distribution  of  state  funding,  is  also  an  issue.  While  public  service  media  is  regulated  by  a 
strong legal framework, there are concerns with regard to potential political influence in the 
appointment of board members. Challenges persist with regard to the adequacy of the media 
regulator’s financial and human resources. 

As regards checks and balances, work on improving the quality of legislation is progressing 
in  particular  as  regards  the  compatibility  of  draft  laws  with  the  Constitution  and  EU  law. 
Codification of legislation is also progressing with the adoption of a number of legal codes in 
different areas of legislation. The number of last-minute amendments for draft legislation is 
decreasing. However, stakeholders are often left  with insufficient time to comment on draft 
laws.  The  Ombudsperson  is  working  on  strengthening  the  capacities  of  the  institution 
including  by  securing  the  independence  of  his  budgetary  resources  and  also  developing 
international  cooperation.  New  legislation  seeks  to  improve  the  framework  of  an  enabling 
environment  for  civil  society  organisations,  although  some  modalities  of  the  registration 
requirements,  continue  to  be  considered  cumbersome  by  some  civil  society  organisations 
while a review of the existing legislation is pending before the Council of State. 

1 

 
RECOMMENDATIONS 

In addition  to  recalling  the commitments made under the national  Recovery and Resilience 
Plan relating to certain aspects of the justice system and the anti-corruption framework, it is 
recommended to Greece to:  

  Address  the  need  for  involvement  of  the  judiciary  in  the  appointment  of  President  and 
Vice-President of the Council of State, the Supreme Court and the Court of Audit taking 
into account European standards on judicial appointments. 

  Ensure the effective and systematic verification of the accuracy of asset disclosures filed 

 

by all types of public officials. 
Increase efforts to establish a robust track record of prosecutions and final judgments in 
corruption cases.  

  Establish  legislative  and  other  safeguards  to  improve  the  physical  safety  and  working 
environment  of  journalists,  in  line  with  the  recently  adopted  Memorandum  of 
Understanding  and  taking  into  account  European  standards  on  the  protection  of 
journalists. 

  Ensure  that  registration  requirements  for  civil  society  organisations  are  proportionate  in 

view of maintaining an open framework for them to operate. 

2 

 
 
 
I. 

JUSTICE SYSTEM 

The Greek judicial system consists of 217 first instance courts (154 magistrate courts and 63 
first-instance courts of general jurisdiction)1. There are 19 second instance courts (courts of 
appeal)  of  general  jurisdiction  and  the  Supreme  Court  as  the  highest  court  of  general 
jurisdiction2. Mixed criminal courts are composed by professional and lay judges3. Within the 
courts of first instance and courts of appeal of large cities, there are special chambers, tasked 
with  adjudicating  in  special  categories  of  law  (e.g.  family  law,  commercial  law,  etc.)4. 
Administrative  courts  are  organised  into  30  administrative  courts  of  first  instance,  9 
administrative courts of appeal  and the Council of State5 which exerts retrospective control 
over  ‘enforceable  acts’  of  administrative  authorities  regarding  their  constitutionality  and 
legality, with the exception of the Acts of Government6. The Court of Audit is the Supreme 
Financial  Court  and  Audit  Institution  auditing  the  use  of  public  funds  in  Greece,  the 
jurisdictional,  auditing  and  advisory  competences 
the 
Constitution.7  Judges  and  prosecutors  form  a  consolidated  body  subject  to  a  system  of 
recruitment, career, rights and obligations, which is largely homogeneous for all. Judges are 
appointed  to  civil  and  penal  jurisdictions  and  to  administrative  courts.  Promotions, 
assignments  to  posts,  transfers  and  secondments,  are  effected  by  presidential  decree  and 
issued  after  prior  decision  by  the  Supreme  Judicial  Council8.  As  regards  prosecution 
authorities,9 they are organised into 63 prosecution offices at the courts of first instance, 19 
prosecution offices at the courts of appeal and the General Prosecutor of the Supreme Court. 
Greece  participates  in  the  European  Public  Prosecutor’s  Office  (EPPO).  There  are  63  bar 
associations in Greece, one at the seat of each court of first instance. 

thereof  being  grounded  on 

1   Ministry of Justice website, https://ministryofjustice.gr/English/. 
2   CEPEJ (2021), Study on the functioning of judicial systems in the EU Member States, p. 638. 
3   Constitution of Greece,  Art.  97, para. 1:  ‘Felonies and political crimes  shall be  tried by  mixed jury courts 
composed of ordinary judges and jurors, as specified by law. The judgments of these courts shall be subject 
to the legal remedies specified by law’. 

4   As far as other special courts are concerned, special provisions regulate the operation of courts for juveniles, 
military, navy and air force courts. The military, navy and air force courts are under the jurisdiction of the 
Ministry  of  National  Defence.  Juvenile  courts  are  part  of  the  courts  of  first  instance  and  do  not  represent 
separate legal entities. CEPEJ (2021), Study on the functioning of judicial systems in the EU Member States, 
p. 638. 

5   Ibid. 
6 

‘Codification of Law concerning the Council of State’, Presidential Decree, 18/1989, Article 45, paragraph 
5.  Acts  of  Government  are  classified  into  three  categories:  (i)  those  concerning  the  relations  between  the 
President  of  the  Republic  with  Parliament  and  the  Government  (e.g.  decree  dissolving  the  Parliament  and 
announcing elections, decree accepting the resignation of a minister or the Government, decree proclaiming 
a referendum, etc.); (ii) acts declaring the mobilisation of the Armed Forces and granting grace; and (iii) acts 
relating  to  international  relations  of  Greece  with  third  countries.  GRECO  Fifth  Evaluation  Round  – 
Evaluation Report, p. 25. 

7   Constitution of Greece, Article 98.  
8   There are three supreme judicial councils, one for each of the branches of the judiciary, which are composed 
only  by  members  of  the  judiciary.  These  councils  decide  on  appointments,  promotions,  transfers  and 
secondments of judges in the respective branches of the judiciary and prosecutors. Constitution of Greece, 
Article 90, paragraph 1. 2020 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 
2-3 and 2021 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 2. 
9   CEPEJ (2021), Study on the functioning of judicial systems in the EU Member States, p. 641. 

3 

 
 
 
                                                 
Independence 

The level of perceived  judicial independence in Greece continues to be average among 
the  general  public  and  is  now  average  among  companies.  Overall,  53%  of  the  general 
population and 59% of companies perceive the level of independence of courts and judges to 
be ‘fairly or very good’ in 202210. According to data in the 2022 EU Justice Scoreboard, no 
clear  trend  can  be  identified  in  the  evolution  of  the  perceived  level  of  independence  since 
2016.  Both  figures  have  decreased  in  comparison  to  2021  (55%  for  the  general  public  and 
60% for companies), but they are higher than in 2016 (47% for the general public and 37% 
for companies). 

The appointments procedures for the highest senior positions of judges and prosecutors 
continue to raise concerns. As reported in the previous Rule of Law Reports, the system of 
appointments  raises  concerns  as  being  subject  to  a  potentially  strong  influence  from  the 
executive11. The relevant legislation12 stipulates that appointments of judges and prosecutors 
in  the  most  senior  positions13  –  such  as  the  President  and  Vice-President  of  the  Council  of 
State,  of  the  Supreme  Court  or  of  the  Court  of  Audit  –  be  effected  by  presidential  decree, 
following a recommendation by the Council of Ministers based on a proposal by the Minister 
of Justice and an opinion of a parliamentary body. There is no involvement of the judiciary in 
the  appointment  procedure  and  the  Constitution  excludes14  unsuccessful  candidates  from 
contesting before an independent court the decision not to recommend them for appointment. 

10   Figures 50 and 52, 2022 EU Justice Scoreboard. The level of perceived judicial independence is categorised 
as  follows:  very  low  (below  30%  of  respondents  perceive  judicial  independence  as  fairly  good  and  very 
good); low (between 30-39%), average (between 40-59%), high (between 60-75%), very high (above 75%). 
11   2020 Rule of  Law  Report,  Country Chapter on the rule of law situation in Greece, p. 3 and 2021 Rule of 
Law Report, Country Chapter on the rule of law situation in Greece, p. 3. In November 2020, GRECO raised 
concerns regarding the system of appointments for the most senior positions in the judiciary (including the 
Supreme  Court  President),  notably  that  these  positions  are  subject  to  a  potentially  strong  influence  of  the 
executive and recommended to revise the method of selection and ensure the involvement of the judiciary in 
the  process,  GRECO  Fourth  Evaluation  Round  -  Second  Compliance  Report,  recommendation  xii,  p.  7. 
More  recently,  the  same  issue  is  raised  by  the  Council  of  Bars  and  Law  Societies  of  Europe  in  its 
contribution for the 2022 Rule of Law Report, p. 30. 

12   The applicable legislation is: i) Constitution of Greece, Art. 90 para. 5, ii) Regulation of the functioning of 
the Greek Parliament, Art. 12 and 13, iii) ‘On the selection of magistrates for the top posts of Justice and the 
reinstatement  of  the  self-governance  on  courts’  Law  3841/2010  and  the  most  recent  iv)  ‘Code  of  the 
organisation  of  the  courts  and  status  of  judges’  Law  4938/2022.  In  practice,  there  is  a  list  of  candidates 
established  by  the  Minister  of  Justice  based  on  seniority.  The  list  is  discussed  by  the  conference  of  the 
Presidents (speakers) of the Parliament. The Minister of Justice is not obliged to follow the opinion of the 
Parliament. The practice of establishing the list of candidates on the basis of seniority has been enshrined in 
the recent Law 4938/2022 (paragraph 3 of Article 59) which provides that:  ‘For promotions to the posts of 
Vice-Presidents of the Council of State, the Supreme Court and the Court of Auditors, the selection shall be 
made from among the ten most senior of the judges who have the formal qualifications, when the post to be 
filled is one. For each additional post, the number of candidates to be selected shall be increased by four.’ 

13   As regards all other members of the judiciary see above p. 3. 
14   Article 90, paragraph 6: ‘Decisions or acts in compliance with the provisions of the present article shall not 
be subject to remedies before the Supreme Administrative Court’. According to the Greek authorities against 
the  presidential  decree  for  the  appointment  to  the  post  of  President  or  Vice-President,  a  petition  for 
annulment  can  be  filed  before  the  Council  of  State,  despite  the  provisions  of  par.  6  of  art.  90  of  the 
Constitution. However, the Court cannot control the exercise of the discretion of the Cabinet with regard to 
the  person  chosen  for  the  post  or  the  evaluated  criteria  for  such  choice.  Are  deemed  admissible,  though, 
grounds  of  annulment  pertaining  to  terms  or  conditions  of  the  promotion  directly  set  by  the  constitutional 
previsions and not by the legislator. 

4 

 
                                                 
 
According  to  European  standards,  an  independent  and  competent  authority  drawn 
substantially  from  the  judiciary  should  be  authorised  to  make  recommendations  or  express 
opinions  which  the  government  follows  in  practice.  In  addition,  an  unsuccessful  candidate 
should have the right to challenge the decision of the Government, or at least the procedure 
under which the decision was made15. These specific issues are  per se not addressed in  the 
new  law  ‘Code  on  the  organisation  of  the  courts  and  the  status  of  judges’  dealing  among 
others  with  the  promotion  of  judges16.  Given  the  fact  that  addressing  the  concerns  would 
imply  the  revision  of  the  Constitution  as  well  as  the  revision  of  the  Regulation  on  the 
functioning  of  the  Parliament,  the  new  Code,  according  to  the  Greek  authorities,  made  the 
effort  to  limit  the  discretionary  power  of  the  Council  of  Ministers  by  including  a  seniority 
criterion  to  the  eligibility  of  the  candidate  judges:  from  now  on,  only  the  most  senior  of 
judges are eligible to  be Vice-President of the Supreme Courts. Similar limitations  are also 
included for the positions of the Presidents of the Supreme Courts.  

Legislation on the organisation of the courts and the status of judges has been adopted. 
The code on the organisation of the courts and the status of judges and prosecutors17 has been 
adopted by the Parliament on 6 June 202218. The legislation aims to have a positive impact on 
the efficiency and quality of justice, in particular as regards the use by judges of digitalised 
procedures  and  the  acceleration  of  the  administration  of  justice19.  In  addition,  the  draft  law 
provides  for  criteria  for  the  promotion  of  judges  and  prosecutors  such  as  quantitative  and 
qualitative performance. These criteria take into consideration the difficulty of the cases the 
judge has dealt with,  efficiency in  the administration of justice and professional  knowledge 
acquired  including  in  the  framework  of  their  participation  to  seminars  organised  by  the 
National School of Judges20.   

The  Council  of  State  and  the  Court  of  Audit are  taking  action  to  ensure  standards  of 
integrity in their members. Following the adoption in 2020 of the Code of Conduct of the 

15   Recommendation  CM/Rec(2010)12  of  the  Committee  of  Ministers  of  the  Council  of  Europe  to  member 

states on judges: independence, efficiency and responsibilities, paras. 46-48. 

16   Art.  59,  paragraph  3  of  the  law  does  not  provide  for  any  changes  as  regards  the  non-involvement  of  the 
judiciary,  the  strong  influence  of  the  executive  and  the  absence  of  legal  remedies  in  the  appointment 
procedure in the most senior positions of judges and prosecutors. For more details on this draft legislation, 
see next paragraph in the main text. 

17   In the framework of the 2021 Rule of Law Report, the Greek authorities indicated that a draft law was under 
preparation, in view of adoption in the third quarter of 2021, in order to amend the ‘Code on the organisation 
of  the  courts  and  the  status  of  judges’  so  as  to  modernise  the  system  of  promotion  for  judges  and 
prosecutors. 2021 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 3-4. 

18   See  also  above.  Written  contribution  from  the  Ministry  of  Justice  in  the  context  of  the  country  visit  to 
Greece. The draft law was also published in the website of the Ministry of Justice. The draft legislation was 
also  examined  in  the  context  both  of  the  enhanced  surveillance  framework  and  is  part  of  the  national 
Recovery and Resilience Plan. European Commission (2022), Enhanced Surveillance Report, Greece, p. 14. 
19   Judges who delay without justification issuing their decisions can face disciplinary procedures, Article 109 

of the legislation. 

20   The  Association  of  Judges  and  Prosecutors  considers  that  the  draft  provisions  on  the  promotion  and  the 
disciplinary  procedures  of  judges  do  not  raise  any  issue  as  regards  the  independence  of  the  judiciary. 
Information received from the Association of Judges and Prosecutors in the context of the country  visit to 
Greece and also written comments on the draft legislation published in the  website of the Association. All 
the  remarks  of  the  Association  were  taken  into  consideration  by  the  Ministry  of  Justice  during  the 
elaboration of the draft. Press release of the Association of Judges of 8 April 2022, published on the website 
of the Association and written contribution from the Ministry of Justice in the context of the country visit to 
Greece, p. 1. 

5 

 
                                                 
Court of Audit, which is currently being implemented21, the Council of State adopted a code 
of conduct for its members on 23 March 202222. Both documents take into consideration the 
best  practices  and  international  texts  in  this  area,  including  the  so-called  ‘Bangalore 
Principles  of  Judicial  Conduct’23.  The  implementation  of  the  codes  of  conduct  takes  place 
under  the  responsibility  of  a  committee.  As  regards  the  Council  of  State,  the  committee 
consists of the President and two councillors proposed by the plenum and the association of 
the judges of the Council of State. As regards the  Court of Audit the committee consists of 
the Vice President and a councillor proposed by the plenum and one judge proposed by the 
association  of  the  judges  of  the  Court  of  Audit24.  As  regards  civil  and  criminal  justice,  the 
work  of  a  special  working  group  established  by  the  President  of  the  Supreme  Court  is 
actively working on the preparation of a code of conduct25. 

Quality 

Digitalisation of administrative justice is well advanced, while further steps are needed 
to address  shortcomings in the digitalisation of all branches  of the judiciary including 
civil justice26.  In administrative justice, centralised case management and case law systems 
are  now  fully  operational  with  a  portal  through  which  all  interested  parties  can  access  a 
unified  Database  of  Administrative  Justice.  Through  the  system,  lawyers  and  public  bodies 
are provided with updated information and can follow up on the case process as well as file 
all  type  of  remedies,  including  appeals,  online  through  the  Hellenic  Bar  Association  portal 
that  authenticates  them  as  lawyers.  Entitled  applicants  can  also  request  legal  aid  via  the 
system.  In  addition,  through  the  same  system  the  handling  of  documents  is  operated 
electronically,  as  is  the  notification  of  decisions  and  the  filing  of  applications  for  issuing 
certificates27.  Lawyers  can  also  lodge  procedural  documents  to  the  administrative  courts 
through the Hellenic Bar Association’s portal28. Fully  anonymised case law is  accessible to 
the public through the administrative justice portal29. As regards civil and criminal courts, a 
new platform30 launched in December 2021 is offering real-time information regarding trial 

21   ‘Charter of deontology of the judges of the Court of Audit’, OJ, 4942B, 09.11.2020. Input from Greece for 
the  2022  Rule  of  Law  Report,  p.  5  and  2021  Rule  of  Law  Report,  Country  Chapter  on  the  rule  of  law 
situation in Greece, p. 4, footnote 22.  

22   Published on the website of the Council of State on 23 March 2022. Written  contribution from the Council 

of State in the context of the country visit to Greece. 

23   In  particular  as  regards  the  core  values  of  the  judiciary:  Independence,  Impartiality,  Integrity,  Propriety, 
Equality,  Competence  and  Diligence.  The  Council  of  State  Code  refers  to  the  ‘Bangalore  Principles’  in 
paragraph  4  and  the  Court  of  Audit  Code  in  paragraph  6  of  the  respective  codes  of  conduct.  For  the 
Bangalore 
see 
https://www.unodc.org/pdf/crime/corruption/judicial_group/Bangalore_principles.pdf. 

principles, 

24   Information received from the Court of Audit and the Council of State in the context of the country visit to 

Greece. 

25   Due  mainly  to the need to restructure the  working  group following the  retirement of some of its  members 
there was some delay. The retired President of the working group has been replaced by the President of the 
Supreme Court in April 2022 and the work on the draft Code has been resumed.   

26   2021 Rule of Law Report, Country Chapter on the rule of law situation in Greece, pp. 4-5. 
27   Contribution from the Association of European Administrative Judges for the 2022 Rule of Law Report, pp. 

12-13. 

28   Input from Greece for the 2022 Rule of Law Report, pp. 11-19. 
29   Ibid;  For  the  website  of  the  administrative  justice  portal  seehttp://www.adjustice.gr/;  Ministry  of  Justice 
(2021), Presentation summary of the Integrated Judicial Management System for Administrative Justice. 
30   dikes.moj.gov.gr (under: portal gov.gr). Any person who wishes to know about a certain trial, has access to 
every case of the daily board of the courts. Anyone interested is offered the possibility to search a case, by a 

6 

 
                                                 
 
boards  and  hearings31.  However,  shortcomings  still  exist  in  civil  justice,  in  particular  as 
regards  the  possibility  for  courts  to  communicate  electronically  between  themselves  in  a 
secure  manner  as  well  as  with  legal  professionals  and  other  institutions,  and  to  the  use  of 
digital  solutions  to  initiate  and  follow  proceedings  in  civil  and  commercial  cases32. 
Digitalisation  of  justice  has  been  identified  as  one  of  the  priority  areas  in  the  national 
Recovery  and  Resilience  Plan  (RRP)33  in  combination  with  an  important  programme  of 
upgrading existing court buildings and the construction of new ones taking into consideration 
digital justice needs34.  

The Government is taking measures aimed at improving access to justice for persons 
with  disabilities.  Persons  with  disabilities  face  difficulties  as  regards  their  access  to 
justice35.  The  Ministry  of  Justice  is  committed  to  continue  improving  the  accessibility  of 
court  buildings  for  persons  with  disabilities  until  2027  to  cover  all  the  court  buildings  of 
Greece. Furthermore, the possibility of enhancing accessibility to deaf and hard-of-hearing 
people  in  courtrooms  through  the  use  of  digitalised  procedures  in  combination  with  the 
existing infrastructure started in 2022 and is planned to be completed in 202636.  

The implementation of the system for the collection of judicial statistics is progressing. 
An  office  for  the  collection  and  processing  of  judicial  statistics  was  established  in  the 
Ministry  of  Justice  at  the  end  of  202037,  with  the  objective  of  systematic  collection  of 
qualitative  and  quantitative  statistical  data38.  The  functioning  of  the  office39  has  been 
formalised with a Presidential Decree40, which is currently being elaborated by the Ministry 
of  Justice.  A  call  for  the  procurement  of  the  relevant  infrastructure  and  services  will  be 
launched in the near future41. 

court  building  number,  or  room  number,  or  even  board  code,  with  no  need  for  authentication  or  special 
registration procedure. 

31   Input from Greece for the 2022 Rule of Law Report, p. 16, www.solon.gov.gr. 
32   Figures  43,  44  and  46,  2022 EU  Justice  Scoreboard.  In  certain  areas  as  for  example  the  issuing  of  digital 
judicial certificates important delays are experienced due mainly to the lack of personnel able to manage the 
relevant  digital  tools.  Information  received  from  the  Bar  Association  in  the  context  of  the  country  visit  to 
Greece. 

33   European Commission, Report on the Ιmplementation of the Recovery and Resilience Facility 2022, p. 40. 
34   Input from Greece for the 2022 Rule of Law Report, pp. 8-9 and information received from the Ministry of 

Justice in the context of the country visit to Greece. 

35   Such  as  the  availability  of  information  in  accessible  formats,  the  availability  of  digital  solutions  for  civil, 
commercial, administrative and criminal cases before first instance courts or the lack of adjusted alternative 
dispute resolution method. Figure 29, 2022 EU Justice Scoreboard. 

36   Input from Greece for the 2022 Rule of Law Report, p. 8-9. 
37   2021 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 5. 
38   This  project  will  be  further  developed  in  the  framework  of  Greece’s  Recovery  and  Resilience  Plan; 
European Commission (2022), Report on the Implementation of the Recovery and Resilience Facility, p. 42. 
39   The office already provides judicial statistics, which are regularly published in the website of the Ministry of 

Justice. 

40   ‘Establishment,  organization  and  operation  of  the  Office  for  the  Collection  and  Processing  of  Judicial 
Statistics  at  the  Central  Service  of  the  Ministry  of  Justice’,  Presidential  Decree  47/2022,  published  in  the 
Government Gazette A' 114/17.06.2022. The Decree provides in Article 4, that the office will be responsible 
for collecting and transmitting judicial statistics to the European Commission for the Efficiency of Justice 
(CEPEJ).  

41   Information received from the Ministry of Justice in the context of the country visit to Greece. 

7 

 
                                                                                                                                                        
The School of Judges was reformed in December 2021 to improve the training of judges. 
The reform of the School of Judges42 aims at increasing the quality of judges’ training. The 
School provides introductory and lifelong training for judges including, for the first time, for 
magistrates43, with regular mandatory training programmes. Ad-hoc training programmes are 
provided  for  judges  of  all  branches  and  ranks  who  are  called  upon  to  implement  new  laws 
and regulations. In addition, international training or further training programmes for judges 
will  be  extended  due  to  the  School's  cooperation  with  the  European  Union  Agency  for 
Asylum  and  the  Academy  of  European  Law44.  The  training  of  trainers  is  established  in 
accordance  with  the  provisions  of  the  European  Network  for  the  Exchange  of  Information 
between  those  responsible  for  providing  Judicial  Training45.  For  the  first  time,  the  list  of 
mandatory courses includes children’s rights as well as principles of child-friendly justice46. 
Ethics and anti-corruption are essential courses in the School’s curriculum47. 

The planned creation of a National  School for Judicial  Clerks aims at ensuring better 
assistance  to  judges.  The  judge/judicial  clerk  ratio  has  been  decreasing  since  2015  and  is 
currently 1.09 judicial clerks per judge48. The aim of the Ministry of Justice is to increase this 
ratio  to  three  judicial  clerks  per  judge49.  The  planned  creation  of  a  National  School  for 
Judicial  Clerks  (NSJC)50  aims  at  increasing  the  quality  of  the  assistance  to  judges  and  the 
quality  of  court  management51.  The  courts  will  have  the  possibility  to  directly  hire  judicial 
clerks from the NSJC. Training and lifelong training of judicial clerks by the NSJC will cover 
topics that are essential for their duties, including the management and organisation of court 
service, digital skills, and procedural and substantive law52. In addition, public sector officials 
will  have  the  possibility  to  be  transferred  to  courts  services  and  become  full  time  judicial 

42   ‘Reform of the National School of Judges’,  Law 4871/2021 of 10 December 2021. For the  website of the 

School of Judges, see https://www.esdi.gr/. 

43   Magistrates chair the magistrate courts which are the lowest jurisdictions.  
44   Since  March  2022,  the  School  has  participated  in  seminars  on  EU  tax  law,  legal  language  training  in 
cooperation  in  Asylum  and  Refugees,  the  Brussels  Ia,  Rome  I  and  II  Regulations,  and  asset  recovery  and 
confiscation 
EU, 
https://www.esdi.gr/%ce%b4%ce%b9%ce%b5%ce%b8%ce%bd%ce%b5%ce%af%cf%82-
%cf%83%cf%87%ce%ad%cf%83%ce%b5%ce%b9%cf%82/. The seminars were organised by the European 
Judicial Training Network (EJTN). 

the 

in 

45   Law 4871/2021 Article 47 and input from Greece for the 2022 Rule of Law Report, pp. 10-11. 
46   Ibid, Article 42c. Also see National School of Judges (2022), ‘Curriculum for the 28th cohort of trainees in 
the administrative justice orientation’, ‘Meetings: c. “EU Charter of Fundamental Rights – Children’s rights 
– Child-friendly justice”’, p. 4; National School of Judges (2022), ‘Curriculum for the 28th cohort of trainees 
in  the  civil  and  criminal  justice  orientation  and  magistrates  orientation’,  ‘Meetings:  c.  “EU  Charter  of 
Fundamental Rights  – Children’s rights  – Child-friendly justice”’, p. 4; National School of Judges (2022), 
‘Curriculum for the 28th cohort of trainees in the prosecution service orientation’, ‘Meetings: c. “EU Charter 
of Fundamental Rights – Children’s rights – Child-friendly justice”’, p. 4. A training seminar on children’s 
rights and child-friendly justice, for judges and prosecutors currently in office, was held between 5-6 May 
2022, https://www.esdi.gr/wp-content/uploads/2022/05/programmsemmap_2022.pdf.  

47   Information received from the representatives of the School of Judges in the context of the country visit to 

Greece. 

48   The  ratio between professional judges and non-judge  staff decreased substantially in Greece from 2015 (1 
judge for 2.53 clerks) to 2020 (1 judge for 1.09 clerk). CEPEJ (2021), Study on the functioning of judicial 
systems in the EU Member States, p. 640. 

49   Input from Greece for the 2022 Rule of Law Report, p. 10-11. 
50   The  Code  of  Judicial  Staff  (Clerks)  was  adopted  on  24  April  2021;  2021  Rule  of  Law  Report,  Country 

Chapter on the rule of law situation in Greece, p.5. 

51   The  NSJC  will be created  with the assistance of the  Recovery and Resilience  Plan  for Greece. Input from 

Greece for the 2022 Rule of Law Report, p. 10. 

52   Ibid. 

8 

 
                                                 
clerks  after  their  evaluation  by  the  relevant  Judicial  Council53.  Officials  specialised  in 
information  technologies  will  also  have  the  possibility  to  be  transferred  to  the  Council  of 
State and to administrative courts54. 

The reform of the judicial map is ongoing. As regards administrative justice, the working 
group on the reform of the judicial map, established by an act of the President of the Council 
of  State  of  24  March  2021,  continues  its  work55.  The  relevant  matters  have  already  been 
under consultation with all administrative courts and are currently under consultation with the 
bar  associations  nationwide56.  As  regards  civil  and  criminal  justice,  the  Ministry  of  Justice 
has signed on 30 March 2022 an agreement with  the  International  Bank for Reconstruction 
and Development for the support of the reform of the judicial map. The technical assistance 
will  propose  an  integrated  plan  for  the  reform  of  the  judicial  map  due  to  be  submitted  for 
consultation with all relevant stakeholders, in order to have a draft law prepared by the end of 
202357. If the reform were to involve a transfer of judges, according to European standards, 
judges  who  would  be  transferred  in  the  course  of  the  reform  without  their  consent  should 
benefit  from  procedural  safeguards  in  order  to  ensure  that  their  independence  is  not 
jeopardised58. 

Efficiency  

Civil  justice  continues  to  face  challenges  regarding  its  overall  efficiency,  while 
improvements are noticed in administrative justice. Judicial statistics show that the civil 
court  system  faces  efficiency  challenges,  as  the  time  needed  to  resolve  litigious  civil  and 
commercial disputes in first instance has increased (637 days in 201959 compared to 559 days 
in  2018)60.  In  administrative  justice,  the  clearance  rate  has  remained  high  (162.8%  in  2020 
compared to 163.5% in 201861) and the disposition time has decreased (to 551 in 2020 from 
601 days in 2018)62.  

The adoption of the reviewed Code of Civil Procedure seeks to introduce improvements 
as regards delays and the coherence of the case law. On 13 October 2021, the new Code of 

53   ‘Code of Judicial Staff’, Law 4798/2021, Article 238. Input from Greece for the 2022 Rule of Law  Report, 

p. 10. 

54   ‘Acceleration  of  pending  judicial  cases’,  Law  4745/2020,  Article  37  and  ‘Speedy  civil  procedures’,  Law 

4842/2021 Article 93. Input from Greece for the 2022 Rule of Law Report, p. 9. 

55   2021 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 5. 
56   Input from Greece for the 2022 Rule of Law Report, p. 17. 
57   Ibid. This specific reform is part of Greece’s Recovery and Resilience Plan. 
58   Pursuant to European standards, it is allowed, in exceptional cases, to transfer judges without their consent, 
provided that sufficient safeguards are in place. These safeguards include a requirement that the judge may 
not  be  transferred  to  a  court  of  a  lower  instance  and  that  he  or  she  has  recourse  to  judicial  review. 
Recommendation  CM/Rec(2010)12  of  the  Committee  of  Ministers  of  the  Council  of  Europe,  para.  52; 
European Charter of the Stature of Judges, Arts. 1.4., 3.4.; European Network of Councils for the Judiciary, 
Development  of  Minimal  Judicial  Standards  III  –  Minimum  Standards  regarding  the  evaluation  of 
professional  performance  and  irremovability  of  members  of  the  judiciary  –  Report  2012-2013,  proposal 
4.21; judgment of the European Court of Human Rights of 9 March 2021,  Bilgen v Turkey, 1571/07, para. 
96. 

59   There is no data available for 2020 for civil and commercial justice. 
60   Figure 6, 2022 EU Justice Scoreboard. 
61   Figure 12, 2022 EU Justice Scoreboard. There are no available data for 2019 for administrative justice. 
62   Figure 8, 2022 EU Justice Scoreboard. 

9 

 
                                                 
Civil  Procedure  was  adopted63  aiming  to  modernise  civil  procedure.  Specific  provisions  of 
the  new  Code  introduce  a  general  use  of  digitalised  procedures64  and  a  number  of  other 
innovations65, namely pilot trials in civil cases66. This procedure allows the Supreme Court to 
decide on a legal matter brought before it by a three-member council67 after an application by 
a  party  to  a  pending  case  or  by  a  preliminary  question  from  a  lower  court  judge.  This 
provision is designed to deal with legal matters that affect a wide circle of parties, with the 
goal of providing legal certainty while at the same time helping with the swift resolution of 
the specific cases68. Taking into consideration the important innovations the Code brings into 
the legal system, training of practitioners including judges and lawyers69 would help the swift 
implementation of the reviewed Code.  

II. 

ANTI-CORRUPTION FRAMEWORK 

The National  Transparency Authority  (NTA)70 oversees the implementation  of the National 
Anti-Corruption Action Plan (NACAP) for 2022-2025, conducts investigations on corruption 
cases,  monitors  the  implementation  of  provisions  related  to  asset  declarations  and  lobbying 
activites,  and  takes  the  necessary  actions  to  ensure  the  coherence  and  effectiveness  of  the 
national  strategy,  with  particular  emphasis  on  coordination  of  control  bodies  and  the 
efficiency of their operations,  and provide relevant  instructions. The Directorate General  of 
Financial  and  Economic  Crime  Unit  (DG  SDOE)  is  the  law  enforcement  agency  of  the 
Ministry of  Finance, whose main focus is  the detection of fraud and corruption cases71.The 

63   ‘Expedited  civil  trial,  adaptation  of  the  provisions  of  civil  procedure  for  the  digitalisation  of  civil  justice, 

other amendments to the Code of Civil Procedure and other urgent provisions’, Law 4842/2021. 

64   Namely, Articles 122A, 959A, 1054 para 4 of Law 4842/2021. 
65   Input from Greece for the 2022 Rule of Law Report, p. 18-19. 
66   Article  20A  of  the  Code.  A  comparative  study  on  legislation  and  practices  concerning  pilot  judgment 
procedures  was  part  of  a  project  of  technical  assistance  the  Commission  has  been  providing  (between  30 
June  2020  and  5  July  2022)  to  the  Greek  Ministry  of  Justice  through  the  general  project  under  the  title 
‘Enhancing  the  reform  of  the  court  system  in  Greece’  funded  under  the  Structural  Reform  Support 
Programme.  The  pilot  trial  procedure  follows  the  example  of  the  same  practice  in  administrative  justice 
which was introduced for the first time with Law 3900/2010,  ‘Rationalization of procedures and expedited 
administrative trial’, Article 1. 

67   Composed of the President of the Supreme Court, the oldest in hierarchy Vice President and the competent 

by substance Vice President or the Prosecutor of the Supreme Court. 

68   The Association of Judges and the Bar Association have expressed their doubts as of the expected efficiency 
of Pilot Trials in civil procedure. They both consider that very few cases would be concerned and this would 
have  a  very  limited  effect  on  the  speeding  of  procedures.  Information  received  from  the  Association  of 
Judges and the Bar Association in the context of the country visit to Greece. The Ministry of Justice agrees 
that  the  procedure  will  be  used  once  or  twice  a  year  but  its  effect  on  the  speeding  of  justice  would  be 
positive. Written input received from the Ministry of Justice following the country visit to Greece. 

69   On 29 March 2022, the Athens Bar Association organised a first training seminar addressed to lawyers on 

the innovations in the civil procedure. See website of the Athens Bar Association, https://www.dsa.gr/. 

70   In  line  with  the  milestone  foreseen  under  the  Greek  Recovery  and  Resilience  Plan  (RRP),  new  business 
premises for NTA shall be developed by the end of 2025. NTA is the Greek designated authority responsible 
for  coordinating  the  fight  against  fraud  (AFCOS)  in  accordance  with  the  Regulation  (EE,  Euratom)  No. 
883/2013  of  the  European  Parliament  and  the  Council  of  September  11,  2013  (EU  L248).  The  NTA  is 
subject to parliamentary scrutiny. 

71   SDOE’s  staff  consists  of  45  employees  serve  at  the  Central  Unit  and  193  employees  and  auditors  at  the 

Operational Directorates. Input from Greece for the 2022 Rule of Law Report, p. 22.  

10 

 
                                                 
Directorate of Internal Affairs is tasked to tackle corruption within the Independent Authority 
for Public Revenue (IAPR)72. 

The perception of public sector corruption among experts and the business community 
is  that  the  level  of  corruption  in  the  public  sector  is  high.  In  the  2022  Corruption 
Perceptions Index by Transparency International, Greece scores 49/100 and ranks 17th in the 
European Union and 58th globally73. This perception has been relatively stable over the past 
five years74. The 2022 Special Eurobarometer on Corruption shows that 98% of respondents 
consider corruption widespread in their country (EU average 68%) and 59% of respondents 
feel  personally  affected  by  corruption  in  their  daily  lives  (EU  average  24%)75.  As  regards 
businesses, 90% of companies consider that corruption is widespread (EU average 63%) and 
76%  consider  that  corruption  is  a  problem  when  doing  business  (EU  average  34%)76. 
Furthermore, 30% of respondents find that there are enough successful prosecutions to deter 
people  from  corrupt  practices  (EU  average  34%)77,  while  19%  of  companies  believe  that 
people  and  businesses  caught  for  bribing  a  senior  official  are  appropriately  punished  (EU 
average 29%)78. 

The anticorruption institutions continue to develop cooperation with private and public 
entities. In 2021, the National Transparency Authority (NTA) continued supporting entities 
in  both  the  public  and  private  sectors79  by  advising  on  fraud  risk  management80  and 
developing anticorruption policies81. In this context, the NTA signed a series of agreements 
with public entities82. In the same year, the Directorate of Internal Affairs of the Independent 
Authority  for  Public  Revenue  has  conducted  85  controls  of  property  of  the  authority 
employees83. 

The new National Anti-Corruption Action Plan (NACAP) for 2022-2025 was approved. 
Following  the  completion  of  the  NACAP  2018-2021,  in  line  with  the  Recovery  and 
Resilience Plan (RRP), in March 2022 the Council of Ministers approved the national Action 

72   Other tasks include  monitoring on disciplinary  misconduct, ensure  the  lawful conduct of its employees, as 

well as to investigate their assets. Input from Greece for the 2022 Rule of Law Report, p. 23.  

73   Transparency  International  (2022),  Corruption  Perceptions  Index  2021,  pp.  2-3.  The  level  of  perceived 
corruption  is  categorised  as  follows:  low  (the  perception  among  experts  and  business  executives  of  public 
sector  corruption scores  above  79);  relatively  low  (scores  between  79-60),  relatively  high  (scores  between 
59-50), high (scores below 50). 

74   In 2017 the score was 48, while in 2021 the score is 49. The score significantly increases/decreases when it 
changes  more  than  five  points;  improves/deteriorates  (changes  between  4-5  points);  is  relatively  stable 
(changes from 1-3 points) in the last five years. 

75   Special  Eurobarometer  523  on  Corruption  (2022).  The  Eurobarometer  data  on  citizens’  corruption 
perception and experience is updated every second year. The previous data set is the Special Eurobarometer 
502 (2020). 

76   Flash Eurobarometer 507 on Businesses’ attitudes towards corruption in the EU (2022). The Eurobarometer 
data on business attitudes towards corruption as is updated every second year. The previous data set is the 
Flash Eurobarometer 482 (2019). 

77   Special Eurobarometer 523 on Corruption (2022).  
78   Flash Eurobarometer 507 on Businesses’ attitudes towards corruption in the EU (2022).  
79   Starting October 2021, NTA delivered six webinars on the integrity in the private sector. Input from Greece 

for the 2022 Rule of Law Report, p. 45. 

80   Information received from the National Transparency Authority in the context of the country visit to Greece. 
81   Ibid. 
82   Input from Greece for the 2022 Rule of Law Report, p. 20.  
83   Information received from the Ministry of Justice in the context of the country visit to Greece. 

11 

 
 
                                                 
Plan  for  2022-202584.  Its  implementation  remains  under  the  remit  of  the  National 
Transparency  Authority.  The  lack  of  comprehensive  involvement  of  civil  society  in  the 
development of anticorruption strategies remains a point of concern85.  

A limited number of prosecutions related to corruption were taken forward, although 
progress  on  final  decisions  remains  to  be  established.  In  December  2021,  the  Criminal 
Code’s  provisions  on  active  and  passive  bribery  were  amended86  in  line  with  the 
recommendations  from  the  Group  of  State  against  Corruption  (GRECO)87.  In  2021,  the 
Prosecutor  for  Financial  Crimes  (with  13  prosecutors  and  13  investigators88)  treated  266 
cases  in  total,  with  81  cases  closed,  and  19  cases  with  charges  pressed,  while  156  cases 
remain  still  pending89.  There  is  no  data  available  on  the  number  of  criminal  sentences  on 
cases of corruption by criminal courts. In September 2021, two cases for active bribery were 
closed due to the statutory limitation90. The OECD has raised concerns on the investigation 
and  the  legislation,  including  sanctions  for  natural  and  legal  persons,  related  to  foreign 
bribery91. 

Asset declarations are filed in great numbers but only a limited percentage of them are  
verified on their accuracy. The system of asset declarations is divided among four oversight 
bodies92.  The  National  Transparency  Authority  (NTA)  is  responsible  for  receiving  and 
verifying the asset declarations of all administrative control authorities (inspectors, auditors, 
investigators). While the completeness of asset declarations is regularly checked, relying on a 
risk-based  assessement,  in  2021  the  NTA  verified  the  accuracy  of  only  139  declarations  of 
assets;  seven  cases  were  referred  to  the  tax  authorities  for  further  investigation,  and  in  one 

84   By  art.1  of  Law  4915/2022,  the  Council  of  Ministers  approved  the  NACAP  2022-2025.  In  the  context  of 
Greece’s RRP, actions concerning the National Anti-Corruption Action Plan are expected to be implemented 
by the end of 2022, namely milestone n.210 on the adoption by the National Transparency Authority of the 
National Anti-Corruption Action Plan for the period 2022-2025, including the specification of: (i) actions to 
enhance  transparency  and  accountability  across  public  administration;  (ii)  targeted  interventions  to  detect 
and prevent corruption in high-risk areas (including, for example, health, public finances, investments); (iii) 
necessary regulatory interventions in selected policy fields. 

85   GRECO Fifth Evaluation Round – Evaluation Report, p. 23, in addition to the information received by civil 
society organisations in the context of the country visit to Greece. According to the Greek authorities there 
were consultations with 24 relevant public and private stakeholders of which 5 Civil Society Organisations. 
86   ‘Amendments to the Penal Code and the Code of Criminal Procedure’, Law 4855/2021, 12 November 2021. 
87   GRECO Fifth Evaluation Round – Evaluation Report, p. 7. 
88   Information received from the Public Prosecutor’s Office in the context of the country visit to Greece.  
89   Ibid. 
90   Information received from the Ministry of Justice in the context of the country visit to Greece. 
91   OECD (2022), Implementing the OECD Anti-Bribery Convention, Phase 4 Report, Greece, p. 5. 
92   There are four main authorities in charge of receiving and auditing asset declarations: i) the Committee of 
Parliament  for  the  Investigation  of  Declarations  of  Assets  (CIDA),  the  so-called  Committee  3-A,  is 
responsible for the oversight and sanctions on political entities’ (such as parties and persons) financing, and 
on  asset  declarations;  ii)  the  Source  of  Funds  Investigation  Unit  (SFIU)  of  the  Anti-Money  Laundering 
Authority, which is responsible for the audit of asset declarations of several categories of public officials, as 
well  as  for  individuals  performing  management  duties  in  specific  private  legal  entities;  iii)  the  Hellenic 
Internal Affairs Agency of Law Enforcement Bodies, which is responsible for the audit of asset declarations 
of Hellenic Police Personnel, Hellenic Coast Guard Personnel and Fire Brigade Personnel, as well as Public 
Servants  of  the  wider  public  sector,  and  (iv)    the  National  Transparency  Authority  who  is  responsible  for 
receiving  and  verifying  the  asset  declarations  of  administrative  control  authorities  (inspectors,  auditors, 
investigators). 2020 and 2021 Rule of Law Reports, Country Chapter on the rule of law situation in Greece, 
p. 7 and p. 8 respectively. 

12 

 
                                                 
case  a  situation  of  conflict  of  interests  was  found93  (compared  to  15  cases  of  non-declared 
revenues and two cases of possible conflict of interest in 2020). The Committee of Parliament 
for  the  Investigation  of  Declarations  of  Assets  (CIDA),  which  is  responsible  for  the 
verification  of  the  asset  declarations  of  Members  of  the  Parliament,  political  parties  and 
members  of  the  judiciary,94  manages  an  annual  workload  of  several  thousands  of 
declarations95. In 2021, it received eight whistleblowing reports, and three questions from the 
members  of  the  judiciary;  four  reports  were  closed  with  no  sanction96,  and  the  other  four 
cases  remain pending97.  In 2021, CIDA verified  23 financial declaration of political  parties 
(for the year 2019), and found eight minor violations on the use of public funds98. In 2021, 
the  Source  of  Funds  Investigation  Unit  of  the  FIU  (SFIU)  of  the  Hellenic  anti-money 
laundering  authority  received  83  528  asset  declarations,  performed  659  verifications  and 
asked  clarifications  for  124  of  the  declarations  verified99.  For  the  same  year,  violations 
(mainly for non-submission) were found in 27 cases, which were forwarded to the competent 
prosecutorial  authorities100.  The  verification  on  the  accuracy  of  the  information  declared  is 
performed only at the request of the prosecutor on an ad hoc basis101. Following verifications 
by  the  Hellenic  Internal  Affairs  Agency  of  Law  Enforcement  Bodies,  34  audit  reports  for 
non-declaration and 56 reports for inaccurate declarations (concerning 727 obligated persons) 
were  transmitted  to  the  prosecution  authorities102.  In  2021,  the  same  unit  received 
approximately  990  complaints  from  whistleblowers  concerning  mainly  cases  of  abuse  of 
power, bribery, drugs dealing  and  gambling, which brought  to open examinations on about 
1 345  cases103.  GRECO  recommends  further  streamlining  the  declarations  of  assets  of 
persons entrusted with top executive functions104. The RRP foresees the revision of the legal 
framework  for  asset  declarations  (Law  3213/2003),  the  simplification  of  the  electronic 

93   In  December  2021,  the  Internal  Regulation  of  Asset  Declaration  Audit  was  updated  after  ‘Common 
Regulation on the Methodology of Asset Declaration Audits’, as well as the Risk Analysis Criteria Manual. 
Information received from the National Transparency Authority in the context of the country visit to Greece, 
and input from Greece for the 2022 Rule of Law Report, p. 36. 

94   2021 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 8. In order to protect 
sensitive  data  of  the  declarants,  the  declarations  of  Members  of  Parliament  are  done  in  a  non-machine 
readable manner. Information received from CIDA in the context of the country visit to Greece. 

95   2021 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 8. 
96   Information received from CIDA in the context of the country visit to Greece. 
97   By the end of 2021, the backlog of 20 000 declarations of assets to be verified was resolved.  2021 Rule of 
Law Report, Country Chapter on the rule of law situation in Greece, p. 8. Information received from CIDA 
in the context of the country visit to Greece. 

98   The findings concerned inaccuracy in the declarations.  The President of the Parliament issued sanctions on 

all eight cases. Information received from CIDA in the context of the country visit to Greece. 

99   Information  received  from  the  Source  of  Funds  Investigation  Unit  in  the  context  of  the  country  visit  to 

Greece. 

100  Information  received  from  the  Source  of  Funds  Investigation  Unit  in  the  context  of  the  country  visit  to 

Greece.  

101  The annual number of asset declarations verified for accuracy varies depending on different elements, such 
as  the  complaints,  prosecutor’s  orders,  complexity  of  cases,  among  others.  Information  received  from  the 
Hellenic Internal Affairs Agency of Law Enforcement Bodies in the context of the country visit to Greece. 
102  Written contribution from the Hellenic Internal Affairs Agency of Law Enforcement Bodies in the context of 

the country visit, p. 1. 

103  Information received  from  Hellenic Internal  Affairs  Agency of  Law Enforcement Bodies in the context of 

the country visit to Greece. 

104  The  GRECO  report  indicates  that  ‘further  initiatives  can  be  taken  to  maximise  synergies  and  enhance 
information exchange on best practice and lessons learned on the basis of the experience already gained by 
the responsible bodies’. ‘Drawing on the experience gained in this area, further streamlining of the system 
and better coordination are desirable’, GRECO Fifth Evaluation Round – Evaluation Report, p. 35. 

13 

 
                                                 
submission process and to upgrade the IT platform for asset declaration and management by 
the end of 2023105. 

Provisions for the regulation of lobbying were adopted, but it is still early to assess their 
implementation.  Following  the  adoption  in  September  2021106  of  the  new  legislation  on 
transparency and accountability, five ministerial implementing decisions were issued for the 
part concerning lobbying. The Ministry of Digital Governance is in the process of developing 
a  specific  platform  for  the  Lobbying  Registry,  which  will  be  managed  by  the  National 
Transparency Authority107. The recently adopted law on lobbying does not mandatorily apply 
to civil society organisations108. In the context of Greece’s RRP, actions aimed to strengthen 
the  implementation  of  lobbying  regulations  (such  as  the  development  of  the  lobbying 
registry) are expected to be developed by the end of 2023. 

Measures on the integrity of civil  servants continue to be taken forward, although the 
conflict  of  interests  system  and  integrity  within  the  police  are  matters  of  concern.  In 
2021,  the  code  of  ethics  and  deontology  was  adopted  for  the  personnel  of  the  General 
Secretariat for Citizenship within the Ministry of Interior as well as that for the Hellenic Food 
Authority109.  In  2021,  the  Ethics  Committee  of  the  National  Transparency  Authority 
examined three cases and imposed a restriction on post-employment in one case110. The new 
legislation  on  enhancing  transparency  and  accountability  regulates  also  the  gift  policy  that 
applies  to  the  President  of  the  Republic,  the  members  of  the  Government  and  the  Deputy 
Ministers111.  In  December  2021,  GRECO  issued  recommendations  on  matters  of  concern 
related to managing conflicts of interest of persons entrusted with top executive functions112, 
including a post-employment regime113. In June 2022 a law was adopted, on the enhancement 

105  These RRP actions aim to streamline the asset declaration process and eliminate excessive and unnecessary 

burden on obligated persons for asset declarations. 

106  ‘Strengthening Transparency and Accountability of State Institutional Bodies’, Law n. 4829 of 10 September 

2021. Input from Greece for the 2022 Rule of Law Report, p. 34.  

107  Information received from the National Transparency Authority in the context of the country visit to Greece. 
108  According  to  the  Ministry  of  Justice,  the  law  covers  lobbying  activities  with  remuneration.  Associations, 
civil  society  organisations  and  other  types  of  non-professional  interest  representatives  may  register  on  a 
voluntary basis and acquire the rights and obligations of professional lobbyists under the Law. Transparency 
International  Greece  expressed concerns that the recently adopted law on lobbying does not apply to non-
professional lobbyists, such as associations, civil society organisations and other types of non-professional 
interest  representatives.  Information  received  from  the  Ministry  of  Justice  and  Transparency  International 
Greece respectively, in the context of the country visit to Greece. 

109  Additionally,  a  general  code  of  conduct  for  officers  in  in  local  and  regional  governance  is  expected  to  be 
published in 2022, in line  with the  milestone  foreseen  under the recovery and resilience plan. Information 
received from the National Transparency Authority in the context of the country visit to Greece.  

110  Written contribution received from the National Transparency Authority in the context of the country visit, 

p. 6. 

111  Supra, part B’ of law 4829/2021. Input from Greece for the 2022 Rule of Law Report, p. 37. NTA and the 
Ministry of the Interior are drafting the  ministerial implementing decisions. Information received from the 
National Transparency Authority in the context of the country visit to Greece and written contribution from 
the National Transparency Authority in the context of the country visit, p. 3. 

112  By  (i)  removing  decision-making  power  from  the  Prime  Minister  and  enhancing  the  competences  of  the 
General  Secretariat  for  Legal  and  Parliamentary  Affairs  of  the  Presidency  of  Government;  (ii)  using 
declarations of conflicts of interest for counselling purposes; (iii) making disqualification decisions available 
to  the  public;  (iv)  articulating  a  complaint  mechanism  by  the  public  or  other  institutions...  GRECO  Fifth 
Evaluation Round - Evaluation Report, pp. 29. 

113  The  post-employment  regime  be  reviewed  in  order  to  assess  its  adequacy  and  that  it  be  strengthened  by 
broadening its scope in respect of persons with top executive functions. GRECO Fifth Evaluation Round - 
Evaluation Report, p. 32. 

14 

 
                                                 
of transparency for high level officials working at the Offices of Members of the Government 
and General Secretaries in Ministries114. It is too early to assess the effectiveness of this new 
law. Moreover, GRECO recommended to address integrity in the Police force, including by 
carrying out a comprehensive risk assessment of corruption in the Police; updating the Code 
of Ethics for the Police; strengthening integrity checks during staff recruitment and to provide 
for  independent  and  effective  investigation  into  police  complaints115.  In  the  context  of 
Greece’s  RRP,  actions  aimed  to  review  policies  and  provisions  on  conflict  of  interests  are 
expected to be implemented by the end of 2024116. 

for 

legislative 

framework 

lacks  a  comprehensive 

Greece 
the  protection  of 
whistleblowers117  and  has  yet  to  transpose  the  Directive  on  the  protection  of 
whistleblowers118.  The  Committee  tasked  to  develop  a  draft  law  on  the  protection  of 
whistleblowers  submitted  the  draft  legislation  to  the  Minister  of  Justice  at  the  end  of  2021 
which is planned to be posted for public consultation in July  2022119. NGOs criticised their 
non-involvement  since  the  early  phase  of  development  of  this  draft  law120.  The  OECD  has 
recently urged Greece to implement new legislation for whistleblowers, for cases of foreign 
bribery121.  GRECO  recommended  Greece  to  strengthen  the  protection  of  whistleblowers 
within the Police122.  

Specific  actions  to  counter  the  risk  of  corruption  during  the  COVID-19  pandemic 
continued  to  be  implemented.  In  June  2021,  the  Hellenic  Single  Public  Procurement 

114 ‘System of evaluation in view of enhancing the efficiency of the public administration’, Law 4940/2022. The 
law aims to ensure integrity  and accountability for  high-level officials, including political advisors, by  the 
publication  of  their  data,  and  by  clarifying  their  obligations,  impediments  and  incompatibilities,  including 
post-employment restrictions.  

115  GRECO Fifth Evaluation Round – Evaluation Report, pp. 42-57. 
116  Actions include development of policy framework, guidelines, toolkit for practitioners; the establishment of 

a national network of Integrity Advisors in the Public Administration. 

117 Whistleblower protection exists in administrative law for the  protection of civil servants against retaliation 
and  in  criminal  law  for  the  protection  of  ‘public  interest  witnesses’  in  penal  cases.  2021  Rule  of  Law 
Reports, country chapter on the rule of law situation in Greece, p. 9. 

118  Directive  (EU)  2019/1937  on  the  protection  of  persons  reporting  on  breaches  of  Union  law,  p.  17.  The 
deadline  for  the  transposition  of  the  Directive  into  national  law  expired  on  17  December  2021. The  Draft 
Law has been submitted to the General Secretariat for Legal and Parliamentary Affairs of the Presidency of 
Government. 

119  Input  from  Greece  for  the  2022  Rule  of  Law  Report,  p.  40  and  written  contribution  from  the  Ministry  of 

Justice in the context of the country visit, p. 3. 

120  Information received from Transparency International Greece in the context of the country visit to Greece. 
However, the Ministry of Justice of Greece argues that the Transparency International Greece was invited to 
submit in writing its proposals, comments or other feedback as to specific points of the Directive so as to be 
taken into consideration by the members of the legislative committee. Despite this invitation,  the NGO did 
not submit any relevant proposal or other material. Information received from the Ministry of Justice in the 
context of the country visit to Greece. 

121  OECD (2022), Implementing the OECD Anti-Bribery Convention, Phase 4 Report, Greece, p. 5. The OECD 
report indicated that ‘To date, no foreign bribery cases have been detected through whistleblower reporting 
in Greece and the situation for whistleblowers remains precarious. During the on-site visit, civil society and 
private sector representatives cited the fear of retaliation and the negative perception of whistleblowers, due 
to  historical  reasons,  as  the  main  reasons  for  the  lack  of  whistleblower  reporting.  Recent  reports  about 
alleged  retaliation  against  the  whistleblowers  in  the  Pharmaceutical  company  case,  and  attempts  to  unveil 
their identity, have caused  greater damage  to the  perception of  whistleblowers and have had an additional 
deterrent effect on those who could potentially report allegations of corruption and foreign bribery’. 

122 GRECO Fifth Evaluation Round – Evaluation Report, pp. 42-57. 

15 

 
                                                 
Authority (HSPPA) issued guidelines123, with the aim of facilitating and assisting the work of 
contracting authorities in the correct implementation of the legislation, so as to avoid risks of 
corruption124. To the same end, the collaboration continues among the NTA, the SDOE, and 
HSPPA. In 2021, 21 targeted audits were performed on specific cases125. 

III.  MEDIA PLURALISM AND FREEDOM 

The Greek legal framework regulating media pluralism is established by the Constitution and 
specific sectorial legislation. The Greek Constitution provides for freedom of expression and 
press freedom126. It also provides for a right of access to information. Restrictions to this right 
may  be  imposed  only  insofar  as  they  are  absolutely  necessary  and  justified  for  reasons  of 
national  security,  combating  crime  or  protecting  the  rights  and  interests  of  third  parties. 
Legislation  transposing  the  Audiovisual  Media  Services  Directive  has  been  in  place  since 
February 2021127.  

There  have  been  no  significant  changes  to  the  legal  framework  regulating  the  media 
regulator  and  concerns  remain  with  regard  to  its  financial  capacity  and  human 
resources.  The  Constitution  guarantees  the  independence  of  the  main  media  regulatory 
body128,  the  National  Council  for  Radio  and  Television  (NCRTV).  According  to  Law 
4779/2021129, NCRTV enjoys full operational independence from the government and from 
any  other  public  and  private  body.  Moreover,  the  NCRTV  exercises  ‘its  responsibilities 
impartially  and  transparently’130.  Although  the  law  implementing  the  Audiovisual  Media 
Services Directive assigns new tasks and responsibilities to the NCRTV, there have been no 
additional  financial  or  human  resources  allocated131  which  would  improve  the  effective 
functioning  and  monitoring  duties  of  the  media  regulator132.  Understaffing  has  been 
highlighted as a matter of concern in a recent publication issued by the European Audiovisual 
Observatory  and  the  European  Platform  of  Regulatory  Authorities  (EPRA)133.  For  these 
reasons,  the  Media  Pluralism  Monitor  (MPM  2022)  considers  the  independence  and 
effectiveness  of  the  media  authority  to  be  an  area  of  medium  risk.134  Concerning  operating 
licencing,  according  to  the  legislation  in  place135,  the  NCRTV  issues  free-to-air  terrestrial 
digital TV licences. The duration of each licence is 10 years. Each licence is granted for the 
purposes  of  a  free-to-air  terrestrial  digital  broadcasting  and  therefore  the  terms  of  its  use 
cannot be modified by the licensee136.  

123  N.27 of June 2021. 
124  Input from Greece for the 2022 Rule of Law Report, p. 42. 
125  Information received from the National Transparency Authority in the context of the country visit to Greece. 
126  Article 14. 
127  2021 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 9. Greece ranks 108th 
in the 2022 Reporters without Borders World Press Freedom Index, compared to 70th in the previous year. 

128  Constitution of Greece, Art. 15(2). 
129  Article 33(1). 
130  Article 33(2) of Law 4779/2021. 
131  The  Greek Government requested the NCRTV to submit an action plan indicating resources and technical 

equipment needed for the new enhanced tasks.  

132  Information received from the NCRTV in the context of the country visit to Greece. 
133  IRIS  Plus  (2021),  Joint  publication  of  the  European  Audiovisual  Observatory  and  the  EPRA:  ‘Media 

regulatory authorities and the challenges of cooperation’, p. 36. 
134  2022 Media Pluralism Monitor, country report for Greece, p. 10. 
135  ‘Licencing operators…’, Law 4339/2015. 
136  Input from Greece for the 2022 Rule of law Report, p. 56. 

16 

 
                                                 
The  Greek  Government  has  taken  some  steps  to  strengthen  transparency  of  media 
ownership.  Legal  safeguards  to  ensure  transparency  of  media  ownership  consist  in  Law 
4779/2021137  which  stipulates  that  media  service  providers  shall  register  in  the  NCRTV’s 
Business  Register.  A  recently  adopted  Law  includes  obligations  for  the  newspapers  to 
expressly  indicate  the  ownership  structure  and  the  legal  representatives138.Media  legislation 
contains safeguards to prevent a high degree of horizontal concentration in the media sector. 
The MPM 2022 indicates a medium risk for news media concentration139. 

The allocation of state advertising raises some concerns. The lack of transparency in the 
distribution of state subsidies to  media outlets  was  highlighted by both  the Media  Freedom 
Rapid  Response  (MFRR)  fact-finding  mission  to  Greece140  and  the  2022  Media  Pluralism 
Monitor  (MPM  2022)141,  pointing  in  particular  to  the  non-transparent  allocation  of  state 
funding for a health awareness campaign during the COVID-19 pandemic. A parliamentary 
inquiry was launched in November 2021, to investigate the funding of media outlets by the 
Government in this context. The competent body of the Hellenic Parliament, established on 
12  November  2021,  stated  that  the  campaign  was  assigned  on  objective  standards  such  as 
quantitative  criteria  on  audience  viewing,  circulation,  affinity  indexes  on  target  groups  as 
well  as  qualitative  criteria  such  as  brand  safety.  However,  the  detailed  information  on  the 
implementation  of  the  public  contract  concerning  the  criteria  used  for  the  distribution  of 
funds and the amount received by the different media have not been entirely disclosed142. A 
request  demanding  the  disclosure  of  the  detailed  award  criteria  filed  by  a  non-profit 
organisation143  was  tacitly  rejected  by  the  authorities.  In  February  2022  the  Administrative 
Court of Appeal of Athens found this rejection to be unlawful  and ordered that the case be 
referred  back  to  the  administration144.  Following  the  Administrative  Court  of  Appeal’s 
decision,  the  National  Transparency  Authority  (NTA)  examined  the  appeal  and  concluded 
that  the  non-profit  organization  could  not  establish  a  legal  right  to  access  the  required 
documentation145. 

Legal safeguards are in place to ensure the independence of Greek public service media 
(ERT),  however  there  are  concerns  with  regards  to  potential  political  influence  in  the 
appointment  of  the  board  members.  The  Greek  public  service  media  is  regulated  by  the 
Law  on  the  Hellenic  Radio  and  Television  which  provides  that  ERT  is  a  limited  liability 
company belonging to the public sector and supervised by the State146. The governing Board 
of ERT comprises seven members: the President, the Managing Director, two representatives 
of ERT’s employees (one of whom shall be a journalist) and three members with specialised 
knowledge and expertise, appointed for a five-year term which can be renewed once147. The 

137  Article 3 of Law 4779/2021.  
138 ‘National Strategic Plan on the fight against corruption’, Law 4915/2022, Article 110. 
139 2022 Media Pluralism Monitor, country report for Greece, p. 12. 
140  Media Freedom Rapid Response (2022), ‘Controlling the Message: Challenges for independent reporting in 
Greece  –  key  findings  from  the  Media  Freedom  Rapid  Response  (MFRR  online  fact-finding  mission  to 
Greece)’, p.12. 

141  2022 Media Pluralism Monitor, country report for Greece, p. 14. 
142  Media Freedom Rapid Response (2022), Controlling the Message: Challenges for independent reporting in 
Greece  –  key  findings  from  the  Media  Freedom  Rapid  Response  (MFRR  online  fact-finding  mission  to 
Greece)’, p. 12. 

143  Greek non-profit organisation Vouliwatch.  
144  Decision no.56/2022 of the Administrative Court of Appeal of Athens. 
145 Decision 16647/7.6.2022 of the Administrative Court of Appeal of Athens. 
146  ‘Regulating the Greek Radio-Television SA’, Law 4324/2015, of 29 April 2015. 
147  Ibid, Article 9. 

17 

 
                                                 
members  of  the  Board  are  appointed  by  the  Minister  responsible  for  the  media  after  the 
Committee  on  Institutions  and  Transparency  of  the  Parliament  has  given  its  opinion  on  the 
Minister’s  recommendation148.  This  procedure  raises  concerns  as  regards  the  independence 
from the Government and potential political influence, as indicated by the MPM 2022, which 
considers  this  to  be  an  area  of  high  risk149.  Safeguards  against  arbitrary  dismissals  are  in 
place150. The monitoring of compliance with program obligations and principles is under the 
responsibility of the NCRTV, which publishes an annual report on ERT’s compliance with its 
obligations.  

Attacks  and  threats  against  journalists  persist151  and  journalists’  professional 
environment has deteriorated further. Since the 2021 Rule of Law Report, 16 alerts have 
been published for Greece on the Council of Europe’s Platform to promote the protection of 
journalism  and  safety  of  journalists152.  They  range  from  physical  attacks153  to  threats  and 
arbitrary  detainment.  Journalists  also  continue  to  face  criminal  lawsuits154  in  the  form  of 
accusations  and  lawsuits  for  defamation  or  violation  of  one’s  privacy  and  exposure  of 
personal  data155.  It  was  moreover  reported  that  one  Greek  journalist  has  been  targeted  by 
spyware  surveillance  software  equivalent  to  Pegasus  (Predator)156,  while  another  journalist 
was allegedly monitored by the national  intelligence service  (EYP)157.  The  Media Freedom 
Rapid  Response  (MFRR)  fact-finding  mission  to  Greece  highlighted  legal  threats  as  a 
significant  problem  for  media  freedom  in  Greece,  including  Strategic  Lawsuits  Against 
Public Participation  (SLAPP)158  targeting mostly  government-critical  outlets and journalists 
who  report  on  corruption159.  Such  legal  threats  can  lead  to  self-censorship  and  pose  an 
additional  economic  risk  to  Greek  media  outlets  and  journalists  who  are  already  under-
resourced160.  Moreover,  respect  for  professional  standards  is  not  effectively  guaranteed161. 

148  Ibid and input from Greece for the 2022 Rule of Law Report, p. 55. 
149 2022 Media Pluralism Monitor, country report for Greece, p. 15. 
150  ‘General Staff Regulation of ERT’, Decision 3150/11.3.2020 of the ERT Board, Articles 23-40.  
151  2021 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 10. 
152  Council of Europe, Platform to promote the protection of journalism and safety of journalists, Greece. 
153  The murder of journalist Giorgos Karaivaz in April 2021 is under investigation by the authorities in Greece, 

and little official information has been made public.  

154  Two recent alerts concern two Journalists who faced criminal conspiracy charges linked to their reporting on 

the Novartis case and the ‘Lagarde list’. The journalists were subsequently acquitted. 
155  Contribution from Reporters without Borders for the 2022 Rule of Law Report, p. 18. 
156  The Greek authorities replied to this alert on 16 June 2022 highlighting that ‘the Greek authorities do not use 
the  specific  software  described  in  these  complaints.  The  Greek  State  does  not  trade  with  any  of  the 
companies that manufacture or market such software’ and ‘the National Transparency Authority has rightly 
intervened on its initiative to investigate the matter’. 

157  Council of Europe, Platform to promote the protection of journalism and safety of journalists, Greece  
158  In November 2021, a Strategic Lawsuit Against Public Participation targeted against the independent media 
outlet  Alterthess.gr  and  its  journalist  Stavroula  Poulimeni  by  a  Greek  gold  mining  executive  convicted  of 
serious environmental crimes, raised serious concerns. See contribution from Reporters without Borders for 
the 2022 Rule of law Report, p. 20. 

159  The Media Freedom Rapid Response (MFRR) online fact-finding mission to Greece took place between 1 
and  15  December  2021  and  was  led  by  the  European  Centre  for  Press  and  Media  Freedom  joined  by 
representatives  of  MFRR  partners  ARTICLE  19,  the  European  Federation  of  Journalists  (EFJ),  the 
International  Press  Institute  (IPI),  the  Osservatorio  Balcani  e  Caucaso  Transeuropa  (OBCT),  and  a 
representative of Reporters without Borders (RSF). 

160  Media Freedom Rapid Response (2022), ‘Controlling the Message: Challenges for independent reporting in 
Greece  –  key  findings  from  the  Media  Freedom  Rapid  Response  (MFRR  online  fact-finding  mission  to 
Greece)’,  p.  5.  According  to  the  Greek  authorities,  following  a  request  from  the  Ministry  of  Justice  the 
National  School  of  Judges  has  already  successfully  completed  2  mandatory  seminars  on  SLAPP  for  all 
judges, magistrates, prosecutors and the candidate judges. 

18 

 
                                                 
The  Greek  Government  has  recently  signed  a  ‘Memorandum  of  Understanding  on  the 
protection,  safety  and  empowerment  of  journalists  and  other  media  professionals’,  which 
contains  a  common  framework  of  cooperation  among  the  different  ministries  including  the 
preparation of proposals for legislative and non-legislative initiatives to ensure the protection 
of  journalists162.  The  MPM  2022  has  highlighted  the  deteriorating  conditions  faced  by 
journalists  as  an  issue  presenting  an  increased  risk163.  Concerns  have  been  expressed  about 
the  risks  for  the  right  of  journalists  to  disseminate  information  of  general  interest  deriving 
from  new  legislation  amending  Article  191  of  the  Greek  Criminal  Code164  aiming  at 
preventing the spread of disinformation. The new provision stipulates that whoever, publicly 
or through the internet, creates or distributes in any way, fake news that may provoke anxiety 
or  fear  in  citizens,  or  shake  citizens’  trust  in  the  national  economy,  or  public  health,  is 
punishable by a prison sentence of at least three months and a fine. Several associations and 
interlocutors interviewed by the MFRR fact-finding mission have expressed serious concerns 
with regard to this provision165. 

IV.  OTHER INSTITUTIONAL ISSUES RELATED TO CHECKS AND BALANCES 

Greece is a parliamentary democracy with a unicameral Parliament. The separation of powers 
is  enshrined  in  the  Constitution  with  legislative  power  vested  in  the  Parliament  and  the 
President. The right to introduce legislation belongs to the Parliament and the Government166. 
All  courts,  irrespective  of  their  position  in  the  judicial  hierarchy,  can  review  the 
constitutionality  of  legislation  and  are  bound  to  disapply  a  law  whose  content  they  deem 
contrary  to  the  Constitution167.  There  are  a  number  of  national  independent  authorities, 
organisations and institutions that aim to  protect and safeguard human rights,  including the 
Greek  National  Commission  for  Human  Rights  accredited  with  A  status  by  the  Global 
Alliance of Human Rights Institutions168.  

Work on improving the quality of the legislative process continues, but stakeholders are 
often left with  insufficient  time to comment on draft legislation. The Committee for the 
Evaluation of the Quality of the Law-making Process169, assessed 49 legislative proposals – 
out of 100 – in the last two years focusing mainly on checking the compatibility of the draft 
laws with the Constitution and EU law, ensuring the coherence of the drafts, in particular as 
regards  the  relevance  of  the  subjects  provided  for170  and  that  the  impact  assessment  is 

161  Contribution from Reporters without Boarders for the 2022 Rule of law Report, p. 18. 
162  The  Memorandum  of  Understanding,  initiated  by  the  Secretariat  General  for  Communication  and  Media 

with the participation of five competent ministries, was signed on 23 May 2022. 

163  2022 Media Pluralism Monitor, country report for Greece, p. 10. 
164  ‘Revision of the criminal code…’ , Law 4855/2021, 12 November 2021. 
165  Contribution from RSF, and from the European Center for Press and Media Freedom (ECPMF) for the 2022 
Rule of law Report, p.10 and  p. 19 respectively.  Media Freedom Rapid Response  (2022),  ‘Controlling the 
Message:  Challenges  for  independent  reporting  in  Greece  –  key  findings  from  the  Media  Freedom  Rapid 
Response (MFRR online fact-finding mission to Greece)’, p. 21. 

166  2021 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 11. 
167  Greek Constitution, Article 93, paragraph 4.  
168  Website of the Global Alliance of Human Rights Institutions, https://ganhri.org/. See Chart of the status of 
national 
2022 
https://www.ohchr.org/sites/default/files/Documents/Countries/NHRI/StatusAccreditationChartNHRIs.pdf.   

Accreditation 

institutions 

status 

April 

27 

of 

as 

– 

169  2021 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 11. 
170  Often legislative proposals in various sections include subjects not related to the main subject. 

19 

 
                                                                                                                                                        
accurate and factually relevant171. The Central Codification Committee172 continued its work 
with the codification173 of a number of legislative texts with the adoption by the Parliament of 
four codes and the elaboration of four draft codes.  Currently, the Committee is  working on 
the elaboration of 20 additional codes174. In addition, the Greek authorities have reported that 
the practice of last-minute amendments submitted to Parliament very close to the end of the 
parliamentary  debate  is  almost  eliminated175,  although  civil  society  organisations  (CSOs), 
including professional associations, often complain not to receive draft legislation in a timely 
manner176. According to the European Network of National Human Rights Institutions, there 
is extensive use of the expedited legislative process by the Government, by which many laws 
have  been  adopted177.  This  process  could  significantly  restrict  the  discussion  in  Parliament 
and  the  timely  consultation  of  stakeholders.  The  Government  is  trying  to  minimise  this 
practice despite the circumstances created by the COVID-19 pandemic178. The quality of law-
making  is  an  important  factor  for  investor  confidence  and  a  reason  for  concern  about 
effectiveness of investment protection for 50% of companies in Greece179.  

The Ombudsperson is working on strengthening the capacities of the institution and its 
international  cooperation.  The  Ombudsperson  submitted  proposals  to  the  Government  in 
December 2021 aiming at further ensuring the autonomy of the Ombudsperson to recruit his 
own  staff  and  at  securing  the  independence  of  his  budgetary  resources,  in  line  with 
recommendations of the Venice Commission180. In parallel, and in order to not rely only on 
the State budget, in November 2021, the Ombudsperson started implementing a project under 

171  Information received from  the Committee  for the  Evaluation of the Quality of the  Law-making Process in 

the context of the country visit to Greece. 

172  2021 Rule of Law Report, Country Chapter on the rule of law situation in Greece, p. 11. 
173 The Ministry of Digital Governance is running the project of the National Portal for Codification and Reform 
of Greek Legislation, which will be the electronic hub of codified legislation, available free of charge to the 
public.  The  project  will  also  include  the  platform  through  which  all  the  law-making  and  regulatory  flows 
will be standardised, the codification will be facilitated, and the operation of the competent authorities will 
be supported. The project is expected to be completed in October 2023. 

174  The four adopted Codes are: 1) Code of legislation for the protection of antiquities and cultural heritage in 
general (Law 4858/2021), 2) Code of legislation on the  financing of political parties (Decree 15/2022), 3) 
Code  of  legislation  for  the  maritime  policy  in  the  island  area  (Law  4832/2021)  and  4)  Code  of 
Administrative  Procedures  of  the  Hellenic  Police  (Decree  103/2021).  Written  input  from  the  Central 
Codification  Committee  in  the  context  of  the  country  visit  to  Greece.  In  addition,  the  Ministry  of  Digital 
Governance has created the  ‘Special Administrative  Codification of  urgent regulatory  measures to prevent 
and limit the  spreading of coronavirus  COVID-19 and to  deal  with relevant problems’,  which contains all 
COVID-19 regulatory measures in a consolidated form. 

175  In 2017, 74% of all amendments were last minute amendments; in 2021 they were reduced to 11% and the 
trend continues in the first three months of 2022 with only 2%. 2021 Rule of Law Report, Country Chapter 
on the rule of law situation in Greece, p. 11; written contribution from the Secretariat General of Legal and 
Parliamentary Affairs in the context of the country visit to Greece, p. 2.  

176  Contribution from the Association of Judges and Prosecutors for the 2022 Rule of Law Report, pp. 11, 12, 
17;  Contribution  from  the  European  Network  of  National  Human  Rights  Institutions  for  the  2022  Rule  of 
Law Report, Greece, p. 290; information received from the Ombudsperson in the context of the country visit 
to Greece. 

177  Contribution from the European Network of National Human Rights Institutions for the 2022 Rule of Law 

Report, Greece, p. 290. 

178  Written  contribution  from the Secretariat General of Legal  and Parliamentary  Affairs  in  the context of  the 

country visit to Greece, p. 2. 

179  Figure  55,  2022  EU  Justice  Scoreboard  indicates  that  ‘Frequent  changes  in  legislation  or  concerns  about 
quality  of  the  law-making  process’  is  a  significant  reason  for  concerns  about  effectiveness  of  investment 
protection among companies in Greece. 

180  Venice  Commission  opinion  (CDL-AD(2019)005),  paragraphs,  21  and  22;  Information  received  by  the 

Ombudsperson in the context of the country visit to Greece. 

20 

 
                                                 
the  programme  ‘Good  Governance,  Institutions  and  Transparency’  of  the  European 
Economic  Area  Financial  Mechanism.  Overall,  the  project  focuses  on  strengthening  the 
capacities of the Ombudsperson both as regards his human resources and the infrastructure. 
The  final  aim  of  the  programme  is  the  capacity  of  the  Ombudsperson  to  further  reduce 
maladministration  in  the  public  sector181.  Given  the  relevance  of  migration  and  asylum  in 
Greece,  the  Ombudsperson  intervenes  on  these  issues  and  recently  published  an  own 
initiative report on allegations of pushbacks182. 

On 1 January 2022, Greece had 34 leading judgments of the European Court of Human 
Rights  pending  implementation183.  At  that  time,  Greece’s  rate  of  leading  judgments  from 
the past 10 years that remained pending was at 35%, and the average time that the judgments 
had been pending implementation was 6 years and 5 months184. The oldest leading judgment, 
pending implementation for 18 years, concerns the access to and the efficient functioning of 
justice  due  to  the  lack  and  the  delayed  enforcement  of  domestic  judicial decisions185.  On 1 
July 2022, the number of leading judgments pending implementation has decreased to 30186. 

The requirements for the registration of CSOs specifically active in the area of asylum, 
migration  and  social  inclusion187  continue  to  raise  concerns  and  the  issue  is  pending 
before the Council of State. The 2021 Rule of Law Report188 noted concerns regarding the 
ability of CSOs active in these areas to operate in Greece and to receive financial support in 
light  of the rules  on the registration and certification introduced in  2020. Three appeals  are 
pending before the Council of State challenging some aspects of the legality of legislation on 
the registration of CSOs189. All these cases were set to be heard by the Plenary Session of the 
Council of State on 3 June 2022 but have been postponed to early December 2022190.  

New legislation raises expectations as regards support to CSOs civil society organisation 
in general, although doubts are expressed by some CSOs on some modalities of the new 
registration  procedure.  A  new  law  which  entered  into  force  in  April  2022191  aims  at 

181  With  the  participation  of  the  European  Union  Agency  for  Fundamental  Rights  (FRA),  the  budget  of  this 
project is EUR 1 938 million. Website of the Ombudsperson and information received from the Ombudsman 
in 
the  Ombudsperson  see 
to  Greece.  For 
https://www.synigoros.gr/en.  

the  country  visit 

the  website  of 

the  context  of 

182  Greek Ombudsman (2022), ‘Special report of the Ombudsman on returns of third-country nationals 2021’. 
183  The adoption of necessary execution  measures  for a  judgment by the European  Court of Human  Rights is 
supervised by the Committee of Ministers of the Council of Europe. It is the Committee’s practice to group 
cases against a State requiring similar execution measures, particularly general measures, and examine them 
jointly. The first case in the group is designated as the leading case as regards the supervision of the general 
measures and repetitive cases within the group can be closed when it is assessed that all possible individual 
measures needed to provide redress to the applicant have been taken. 

184  All figures are calculated by the European Implementation Network and are based on the number of cases 
that  are  considered  pending  at  the  annual  cut-off  date  of  1  January  2022.  See  Contribution  from  the 
European Implementation Network for the 2022 Rule of Law Report, p. 46. 

185  Judgment of the European Court of Human Rights of 27 March 2003, Satka and Others v. Greece, 55828/00, 

pending implementation since 2003. 

186  Data according to the online database of the Council of Europe (HUDOC). 
187  2021 Rule of Law Report, Country Chapter on the rule of law situation in Greece, pp. 12-13. 
188  Ibid.  
189  Ibid. 
190  Input from Greece for the 2022 Rule of Law Report, p. 66. 
191  Adopted on 16 December 2021,  ‘Protection of volunteering, strengthening the action of the  Civil  Society, 
tax  incentives  for  the  strengthening  of  the  public  benefit  action  of  the  CSOs  and  other  provisions’,  Law 
4873/2021. 

21 

 
                                                 
supporting  all types  of  CSOs. The law establishes a new database  and a public registry  for 
CSOs,  introduces  state  financial  support  and  tax  exemptions,  and  provides  monetary 
incentives  to  private  actors  in  order  to  encourage  donations  to  CSOs.  While  it  is  not 
mandatory  for  CSOs  to  register  in  the  new  database  and  registry,  only  registered 
organisations  benefit  from  the  tax  exemptions  and  may  request  state  financial  support.  The 
registration  is  subject  to  certain  conditions  and  administrative  requirements  which  aim  at 
strengthening transparency but some modalities have been criticised as overly cumbersome, 
especially for smaller CSOs which lack the necessary administrative capacity192. The result is 
that  the  civil  society  space  is  considered  to  be  narrowed193.  More  than  300  CSOs  signed  a 
statement194 before the adoption of the law urging the Government to reconsider its rationale. 
They argue that the law impinges on the independence of CSOs, creates an uneven playing 
field  and  a  two-speed  civil  society,  to  the  detriment,  in  particular,  of  smaller  and  newly 
formed CSOs, and fails to establish an appropriate framework for the interaction of state and 
civil  society195.  While  the  Ombudsperson  has  a  generally  positive  position  on  the  new 
legislation,  in  particular  as  regards  transparency,  the  Ombudsperson  considers  that  the 
concerns of some CSOs related to the requirements for registration could be cumbersome for 
smaller entities196. In addition, following a new law of 4 September 2021197, CSOs providing 
services  in  areas  within  the  competence  of  the  Hellenic  Coastguard,  especially  NGOs 
engaged  in  search  and  rescue  missions  at  sea,  have  the  obligation  to  act  only  after  prior 
authorisation  of  the  Hellenic  Coastguard.  If  the  NGOs  in  question  do  not  respect  this 
obligation, the responsible persons face penalties that could entail a custodial sentence up to 
one year198.  

192  Contribution from the  European Union Agency  for Fundamental Rights for the 2022 Rule of Law Report, 
‘legal environment and space of civil society organisations in supporting fundamental right and the rule of 
law’, Greece, p. 6. 

193  Rating by CIVICUS; ratings are on a five-category scale defined as: open, narrowed, obstructed, repressed 

and closed. Civicus (2022), Monitor tracking civic space-Greece. 

194  Franet (2022), Country research  – legal environment and space of civil society organisations in supporting 
fundamental rights – Greece, p. 6; Higher Incubator Giving Growth & Sustainability (HIGGS) (2021), ‘Joint 
Statement of 303 organisations on the new bill on CSOs’. 

195  Contribution from European Civic Forum for the 2022 Rule of Law Report, Greece, p. 3. 
196  Information received from the Ombudsperson in the context of the country visit to Greece.  
197  ‘Revision of expulsion proceedings …. ‘, Law 4825/2021 (Article 40). 
198  The criminalisation of certain rescue at sea activities of CSOs has been criticised by the Ombudsman (in his 

annual report published on 31 December 2021).. 

22 

 
 
 
                                                 
Annex I: List of sources in alphabetical order* 

*The list of contributions received in the context of the consultation for the 2021 Rule of Law report 
can  be  found  at  https://ec.europa.eu/info/publications/2022-rule-law-report-targeted-stakeholder-
consultation_en.  

Administrative Court of Appeal of Athens, decision no. 56/2022. 

Association  of  European  Administrative  Judges  (2022),  Contribution  from  the  Association  of 
European Administrative Judges for the 2022 Rule of Law Report. 

Association  of  Judges  and  Prosecutors  (2022),  Contribution  from  the  Association  of  Judges  and 
Prosecutors for the 2022 Rule of Law Report. 

Association  of  Judges  and  Prosecutors  (2022),  Press  release  of  8  April  2022  ‘Outcome  of  meeting 
with the Minister of Justice regarding the new Code on the organisation of the courts and the status of 
judges and prosecutors’  (‘Τα αποτελέσματα της συνάντησης με τον Υπουργό Δικαιοσύνης για τον νέο 
Κώδικα 
Λειτουργών’) 
Κατάστασης 
https://ende.gr/%ce%b4%ce%b5%ce%bb%cf%84%ce%b9%ce%bf-
%cf%84%cf%85%cf%80%ce%bf%cf%85-%cf%84%ce%b1-
%ce%b1%cf%80%ce%bf%cf%84%ce%b5%ce%bb%ce%ad%cf%83%ce%bc%ce%b1%cf%84%ce%
b1-%cf%84%ce%b7%cf%82-%cf%83%cf%85%ce%bd%ce%ac/.   

Δικαστηρίων 

Οργανισμού 

Δικαστικών 

και 

Centre  for  Media  Pluralism  and  Media  Freedom  (2021),  Media  pluralism  monitor  2021  –  country 
report for Greece. 

Centre  for  Media  Pluralism  and  Media  Freedom  (2022),  Media  pluralism  monitor  2022  –  country 
report for Greece. 

CEPEJ (2021), Study on the functioning of judicial systems in the EU Member States. 

Civicus (2022), Monitor tracking civic space-Greece https://monitor.civicus.org/country/greece/.  

Council of Bars and Law Societies of Europe (CCBE) (2022), Written contribution from the Council 
of Bars and Law Societies of Europe for the 2022 Rule of Law Report in the context of the country 
visit. 

Council  of  Europe:  Committee  of  Ministers  (2010),  Recommendation  CM/Rec(2010)12  of  the 
Committee of Ministers to member states on judges: independence, efficiency and responsibilities. 

Council  of  Europe,  Platform  to  promote  the  protection  of  journalism  and  safety  of  journalists  – 
Greece https://fom.coe.int/en/alerte?years=2022&typeData=1&time=1653914309287.  

Council  of  Europe: Venice  Commission  (2019),  Principles  on  the  Protection  and  Promotion  of  the 
Ombudsman Institution (the Venice Principles) (CDL-AD(2019)005). 

Council of State (2022), Contribution from the Council of the State for the 2022 Rule of Law Report. 

Council  of  State  (2022),  Code  of  Conduct  (Χάρτης  Δεοντολογίας  των  Δικαστικών  Λειτουργών  του 
Συμβουλίου 
Επικρατείας) 
της 
http://www.adjustice.gr/webcenter/portal/ste/pageste/epikairotita/anakoinwseis?contentID=SNEWS-
TEMPLATE1648040999911&_afrLoop=31807212245395061#!%40%40%3F_afrLoop%3D3180721
2245395061%26centerWidth%3D65%2525%26contentID%3DSNEWS-
TEMPLATE1648040999911%26leftWidth%3D0%2525%26rigthWidth%3D35%2525%26showFoot
er%3Dfalse%26showHeader%3Dtrue%26_adf.ctrl-state%3Djsbrkd45o_446.        

Directive (EU) 2019/1937 of the European Parliament and of the Council, of 23 October 2019 on the 
protection of persons reporting on breaches of Union law, OJ L 305. 

Directorate-General  for  Communication  (2019),  Flash  Eurobarometer  482:  Businesses'  attitudes 
towards corruption in the EU. 

Directorate-General for Communication (2020), Special Eurobarometer 502: Corruption. 

23 

 
Directorate-General  for  Communication  (2022),  Flash  Eurobarometer  507:  Businesses'  attitudes 
towards corruption in the EU. 

Directorate-General for Communication (2022), Special Eurobarometer 523: Corruption. 

European  Civic  Forum  (2022),  Contribution  from  the  European  Civic  Forum  for  the  2022  Rule  of 
Law Report. 

European Commission (2020), 2020 Rule of Law Report, Country Chapter on the rule of law situation 
in Greece. 

European Commission (2021), 2021 Rule of Law Report, Country Chapter on the rule of law situation 
in Greece. 

European Commission (2022), Report on the implementation of the Recovery and Resilience Facility. 

European Commission (2022), EU Justice Scoreboard. 

European Commission (2022) Enhanced Surveillance Report, Greece. 

European  Court  of  Human  Rights,  judgment  of  27  March  2003,  Satka  and  Others  v.  Greece, 
55828/00. 

European Court of Human Rights, judgment of 9 March 2021, Bilgen v Turkey, 1571/07. 

European Implementation Network (2022), Contribution from the European Implementation Network 
for the 2022 Rule of Law Report. 

European Network of Council for the Judiciary (ENCJ), Development of Minimal Judicial Standards 
III  -  Minimum  Standards  regarding  evaluation  of  professional  performance  and  irremovability  of 
2012-2013 
members 
https://www.encj.eu/images/stories/pdf/workinggroups/final_report_encj_project_minimum_standard
s_iii_corrected_july_2014.pdf.  

judiciary 

Report 

the 

of 

– 

European  Network  of  National  Human  Rights  Institutions  (2022),  Contribution  from  the  European 
Network of National Human Rights Institutions for the 2022 Rule of Law Report. 

Franet,  Centre  for  European  Constitutional  Law  (2022),  Country research  -  Legal  environment  and 
space of civil society organisations in supporting fundamental rights  – Greece, Vienna, EU Agency 
for  Fundamental  Rights  https://fra.europa.eu/en/publication/2022/civic-space-2022-update#country-
related.  

Global  Alliance  of  Human  Rights  Institutions  (2022),  Chart  of  the  status  of  national  institutions  – 
2022 
Accreditation 
https://www.ohchr.org/sites/default/files/Documents/Countries/NHRI/StatusAccreditationChartNHRI
s.pdf.   

status 

April 

27 

as 

of 

Greek Government (2022), Input from Greece for the 2022 Rule of Law Report. 

Greek  Ombudsman  (2021),  Annual  report  2021  (Η  ετήσια  έκθεση  του  Συνηγόρου  του  Πολίτη  για  το 
2021) https://www.synigoros.gr/?i=stp.el.annreports.945511.  

Greek  Ombudsman  (2022),  Special  report  of  the  Ombudsman  on  returns  of  third  country  nationals 
2021) 
(Ειδική  Έκθεση  Συνηγόρου 
https://www.synigoros.gr/el/category/default/post/special-report-2021-on-returns-of-third-country-
nationals.  

τις  Επιστροφές  Αλλοδαπών 

του  Πολίτη 

για 

GRECO  (2020),  Fourth  Evaluation  Round  –  Second  Compliance  Report  on  Greece  on  preventing 
corruption in respect of members of parliament, judges and prosecutors. 

GRECO  (2022),  Fifth  Evaluation  Round  –  Evaluation  Report  on  Greece  on  preventing  corruption 
and  promoting  integrity  in  central  governments  (top  executive  functions)  and  law  enforcement 
agencies. 

24 

 
Higher  Incubator  Giving  Growth  &  Sustainability  (HIGGS)  (2021),  Joint  statement  of  303 
organisations on the new bill on CSOs  (Κοινή Δήλωση 303 Οργανώσεων για το νέο Νομοσχέδιο της 
ΚτΠ) https://higgs3.org/koini-dilosi-287-organoseon-gia-to-neo-nomoschedio-tis-ktp/.   

Hellenic Internal Affairs Agency of Law Enforcement Bodies (2022), Written contribution from the 
Hellenic Internal Affairs Agency of Law Enforcement Bodies for the 2022 Rule of Law Report in the 
context of the country visit. 

IRIS  plus  (2021),  Joint  publication  of  the  European  Audiovisual  Observatory  (EAO)  and  the 
European  Platforms  of  Regulatory  Authorities  (EPRA)  -  Media  regulatory  authorities  and  the 
challenges  of  cooperation  https://rm.coe.int/iris-plus-2021en2-media-regulatory-authorities-and-the-
challenges-of-c/1680a55eb1.  

Media  Freedom  Rapid  Response  (2022),  Controlling  the  Message:  Challenges  for  independent 
reporting  in  Greece  –  key  findings  from  the  Media  Freedom  Rapid  Response  (MFRR  online  fact-
finding  mission  to  Greece)  https://www.mfrr.eu/controlling-the-message-challenges-for-independent-
reporting-in-greece/.  

Ministry  of  Justice,  Presentation  summary  of  the  Intergrated  Judicial  Management  System  for 
Administrative Justice (Σύνοψη παρουσίασης για το Ολοκληρωμένο Σύστημα Διαχείρησης Δικαστικών 
Υποθέσεων για τη Διοικητική Δικαιοσύνη) https://www.ministryofjustice.gr/?page_id=3014.  

Ministry of Justice (2022), Written contribution from the Ministry of Justice for the 2022 Rule of Law 
Report in the context of the country visit. 

National Audiovisual Regulator (ERT), General Staff Regulation of ERT, Decision 3150/11.3.2020. 

National  School  of  Judges  (2022),  Curriculum  for  the  28th  cohort  of  trainees  in  the  administrative 
justice 
Διοικητικής  Κατεύθυνσης) 
https://www.esdi.gr/wp-content/uploads/2022/03/2o_stadio_dioik28cc-1.pdf.  

(Πρόγραμμα 

orientation 

Σπουδών 

Σειράς 

28ης 

National School of Judges (2022), Curriculum for the 28th cohort of trainees in the civil and criminal 
justice  orientation  and  magistrates  orientation  (Πρόγραμμα  Σπουδών  28ης  Σειράς  Κατευθύνσεις 
Πολιτικής-Ποινικής 
https://www.esdi.gr/wp-
και 
content/uploads/2022/03/1_stadio_28poleir.pdf.  

Ειρηνοδικών) 

Δικαιοσύνης 

National School of Judges (2022), Curriculum for the 28th cohort of trainees in the prosecution service 
orientation  (Πρόγραμμα  Σπουδών  28ης  Σειράς  Κατεύθυνση  Εισαγγελέων)  https://www.esdi.gr/wp-
content/uploads/2022/03/1o_stadio_eisagg28.pdf.  

National  Transparency  Authority  (2022),  Written  contribution  from  the  National  Transparency 
Authority for the 2022 Rule of Law Report in the context of the country visit. 

OECD  (2022),  Implementing  the  OECD  Anti-Bribery  Convention,  Phase  4  Report  Greece 
https://www.oecd.org/daf/anti-bribery/Greece-Phase-4-Report-EN.pdf.  

Public Prosecutor’s Office (2022), Contribution from the Public Prosecutor’s Office for the 2022 Rule 
of Law Report. 

Regulation (EU, Euratom) No 883/2013 concerning investigations conducted by the European  Anti-
Fraud Office (OLAF). 

Reporters without Borders – Greece https://rsf.org/en/country/greece.   

Reporters without Borders (2022), Contribution from Reporters without Borders for the 2022 Rule of 
Law Report. 

Secretariat  General  of  Legal  and  Parliamentary  Affairs  (2022),  Written  contribution  from  the 
Secretariat  General  of  Legal  and  Parliamentary  Affairs  for  the  2022  Rule  of  Law  Report  in  the 
context of the country visit. 

Transparency International (2022), Corruption Perceptions Index 2021. 

25 

 
United  Nations  Office  on  Drugs  and  Crime,  Bangalore  Principles  of  Judicial  Conduct 
https://www.unodc.org/pdf/crime/corruption/judicial_group/Bangalore_principles.pdf.   

26 

 
 
Annex II: Country visit to Greece 

The Commission services held virtual meetings in March 2022 with: 

  Athens Bar Association 
  Central Codification Committee 
  Committee for the Evaluation of the Quality of the law-making process 
  Committee  of  Parliament  for  the  Investigation  of  Declarations  of  Assets  (CIDA,  or 

Journalists’ Union ESIEMTH 

Committee 3-A). 
  Council of State 
  Court of Audit 
  Greek Association of Judges 
  Greek Bar Association 
  Hellenic Internal Affairs Agency of Law Enforcement Bodies 
 
  Ministry of Justice 
  National Audiovisual Regulator 
  National School of Judges 
  National Transparency Authority 
  Ombudsman 
  PRAKSIS 
  Prosecutor for Financial Crimes and the Financial Police Division 
  Prosecutor's Office to the Supreme Court 
  Refugee Support Aegean 
  Supreme Court 
  Transparency International Greece 

* The Commission also met the following organisations in a number of horizontal meetings: 

  Article 19  
  Civil Liberties Union for Europe 
  Civil Society Europe  
  European Centre for Press and Media Freedom  
  European Civic Forum 
  European Federation of Journalists  
  European Partnership for Democracy 
  European Youth Forum 
  Free Press Unlimited 
  Human Rights Watch  
 
 
 
  Open Society European Policy Institute ( OSEPI) 
  Osservatorio Balcani e Caucaso Transeuropa  
  Philea 
  Reporters Without Borders 
  Transparency International Europe 

ILGA Europe 
International Federation for Human Rights (FIDH) 
International Press Institute 

27